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Tax

Transfer Pricing Policy & Structuring

Documentation explains what you did. A policy decides what you will do. We design the pricing policy for your intra-group arrangements and make it something your finance team can apply month to month.

Why it matters

Why Transfer Pricing Policy & Structuring matters

Most transfer pricing difficulty is created upstream, by arrangements that were never designed — they simply accumulated.

Consistency is easier to defend

A policy applied the same way each period tells a coherent story. Ad hoc charges do not.

The policy has to be operable

If finance cannot apply it in a normal close, it will not be applied. We design for that.

Design beats remediation

Setting the arrangement up correctly costs a fraction of unwinding it later.

What we provide

What the engagement covers

Current-state review

The intra-group arrangements you actually have, mapped and characterised.

Policy design

Methods, rates and mechanics defined for each category of transaction.

Intercompany agreements

The arrangements written down, so the paperwork matches the practice.

Operating guidance

A practical note for the finance team covering how charges are calculated and posted.

Implementation support

We help apply it through the first cycles rather than handing over a document.

Outcomes

What you get

  • Intra-group pricing that is decided rather than inherited

  • Agreements that match what actually happens

  • A policy your finance team can run at close

  • Fewer surprises when documentation is prepared

Who it is for

Built for businesses like yours

  • Groups formalising intra-group arrangements for the first time

  • Businesses adding a UAE entity to an existing group

  • Companies whose intra-group charges vary period to period

  • Groups restructuring where functions are moving between entities

Questions

Transfer Pricing Policy & Structuring: common questions

They do different jobs. Documentation defends what happened; a policy determines what happens next. Groups with documentation but no policy tend to rebuild the analysis every year.

Yes. A policy that is not reflected in signed agreements is difficult to sustain, so the two are usually done together.

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